arXiv — NLP / Computation & Language · · 3 min read

From Obligation to Specification: A Survey on Validating EU AI Act Requirements in RE

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Computer Science > Software Engineering

arXiv:2607.21608 (cs)
[Submitted on 18 May 2026]

Title:From Obligation to Specification: A Survey on Validating EU AI Act Requirements in RE

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Abstract:With the EU AI Act entering into force, organizations developing or operating AI systems face new obligations on transparency, risk management, and traceability. For Requirements Engineering (RE), these obligations must be translated into testable, auditable requirements and verifiable evidence. However, many organizations currently lack systematic processes to achieve this. We hypothesize that LLM-based agentic validation tools can support this translation, thereby helping to close this gap. We present a mixed-method exploratory study with expert interviews (N=10) and an online survey (N=15) to assess organizational preparedness for EU AI Act-oriented RE and perceptions of LLM-based, agentic closed-loop validation tools, with participants spanning RE, data science, development, and compliance roles. Our results show that, although the EU AI Act is viewed as highly relevant, structured mechanisms to capture regulatory obligations, propagate updates into projects, and maintain lifecycle-wide traceability and evidence are often missing. Participants see LLM-based tools as promising for mapping obligations to requirements, assessing coverage, and organizing evidence, but express strong concerns about full automation and stress the need for safeguards. Based on these findings, we outline minimum requirements for an EU AI Act-ready closed-loop approach.
Subjects: Software Engineering (cs.SE); Artificial Intelligence (cs.AI); Computation and Language (cs.CL); Computers and Society (cs.CY)
Cite as: arXiv:2607.21608 [cs.SE]
  (or arXiv:2607.21608v1 [cs.SE] for this version)
  https://doi.org/10.48550/arXiv.2607.21608
arXiv-issued DOI via DataCite

Submission history

From: T.Y. Emmy Lai [view email]
[v1] Mon, 18 May 2026 13:02:16 UTC (6,215 KB)
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